Chicago Pneumatic India Ltd. v. DCIT

15 SOT 252Income Tax Appellate Tribunal2007#959 most cited

What is Chicago Pneumatic India Ltd. v. DCIT authority for?

The Assessing Officer must grant the correct deduction after due verification of claims made by the assessee, even if not perfectly articulated initially. This principle applies in assessment proceedings, including those involving specific deductions like those for export-oriented units under Section 10B.

111

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2015 to 2025.

Also referred to as

Chicago Pneumatic India Ltd v DCIT · 15 SOT 252 · ITAT Mumbai · Assessing Officer duty to verify · correct deduction · Section 10B · export oriented undertaking · assessment procedure · assessee claim verification · Section 143(3)

Sections most often in play

Section 143(3)Section 153ASection 153CSection 132Section 147Section 143(1)Section 132(4)Section 139(5)

Issues it is cited on

section 153(a)(1)section 8d(2)(ii)section 17(2)(iiia)section 10b(8)section 8dsection 9(1)(ii)section 17(2)section 158bb(1)section 5(b)section 153(a)retraction of statementsection 153a(1)(a)

Judgments citing Chicago Pneumatic India Ltd. v. DCIT

John Developers, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(1), Bangalore

ITA 846/BANG/2023[2015-16]Status: DisposedITAT Bangalore24 Jul 2024AY 2015-16

…of the assessee and that it was one of the duties of the officers to assist the tax payers in determination of correct amount of tax payable, as per law. Ld. CIT(A) also followed the judgment of Mumbai Bench of ITAT in Chicago Pneumatic (India) Ltd. v. DCIT, 15 SOT 252, wherein relying upon the said circular the Hon’ble Bench had observed that assessing authorities are bound to compute the correct income, and merely for a procedural lapse on technicalities, the assessee should not be compelled to pay more taxes than what is due from him. 4. It is further noted by us that in A.Y 2008-09 an identical claim was mad…

John Developers, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(1), Bangalore

In the result, appeals of the assessee in ITA No

ITA 845/BANG/2023[2014-15]Status: DisposedITAT Bangalore24 Jul 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Keshav Dubey

…of the assessee and that it was one of the duties of the officers to assist the tax payers in determination of correct amount of tax payable, as per law. Ld. CIT(A) also followed the judgment of Mumbai Bench of ITAT in Chicago Pneumatic (India) Ltd. v. DCIT, 15 SOT 252, wherein relying upon the said circular the Hon'ble Bench had observed that assessing authorities are bound to compute the correct income, and merely for a procedural lapse on technicalities, the assessee should not be compelled to pay more taxes than what is due from him. 4. It is further noted by us that in A.Y 2008-09 an identical claim was ma…

M/S. Paul Resorts & Hotels Pvt Ltd, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(1), Bangalore

In the result, appeals of the assessee in ITA No

ITA 841/BANG/2023[2014-15]Status: DisposedITAT Bangalore24 Jul 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Keshav Dubey

…of the assessee and that it was one of the duties of the officers to assist the tax payers in determination of correct amount of tax payable, as per law. Ld. CIT(A) also followed the judgment of Mumbai Bench of ITAT in Chicago Pneumatic (India) Ltd. v. DCIT, 15 SOT 252, wherein relying upon the said circular the Hon'ble Bench had observed that assessing authorities are bound to compute the correct income, and merely for a procedural lapse on technicalities, the assessee should not be compelled to pay more taxes than what is due from him. 4. It is further noted by us that in A.Y 2008-09 an identical claim was ma…

M/S. Paul Resorts & Hotels Pvt Ltd, Bangalore vs. Deputy Commissioner of Income-Tax, Central Circle-1(1), Bangalore

In the result, appeals of the assessee in ITA No

ITA 840/BANG/2023[2013-14]Status: DisposedITAT Bangalore24 Jul 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Keshav Dubey

…of the assessee and that it was one of the duties of the officers to assist the tax payers in determination of correct amount of tax payable, as per law. Ld. CIT(A) also followed the judgment of Mumbai Bench of ITAT in Chicago Pneumatic (India) Ltd. v. DCIT, 15 SOT 252, wherein relying upon the said circular the Hon'ble Bench had observed that assessing authorities are bound to compute the correct income, and merely for a procedural lapse on technicalities, the assessee should not be compelled to pay more taxes than what is due from him. 4. It is further noted by us that in A.Y 2008-09 an identical claim was ma…

M/S. Paul Resorts & Hotels Pvt Ltd, Bangalore vs. Deputy Commissioner of Income-Tax, Central Circle-1(1), Bangalore

In the result, appeals of the assessee in ITA No

ITA 839/BANG/2023[2012-13]Status: DisposedITAT Bangalore24 Jul 2024AY 2012-13

Bench: Shri Chandra Poojari & Shri Keshav Dubey

…of the assessee and that it was one of the duties of the officers to assist the tax payers in determination of correct amount of tax payable, as per law. Ld. CIT(A) also followed the judgment of Mumbai Bench of ITAT in Chicago Pneumatic (India) Ltd. v. DCIT, 15 SOT 252, wherein relying upon the said circular the Hon'ble Bench had observed that assessing authorities are bound to compute the correct income, and merely for a procedural lapse on technicalities, the assessee should not be compelled to pay more taxes than what is due from him. 4. It is further noted by us that in A.Y 2008-09 an identical claim was ma…

M/S. Paul Resorts & Hotels Pvt. Ltd., Bangalore vs. Deputy Commissioner of Income-Tax, Central Circle-1(1), Bangalore

In the result, appeals of the assessee in ITA No

ITA 838/BANG/2023[2011-12]Status: DisposedITAT Bangalore24 Jul 2024AY 2011-12

Bench: Shri Chandra Poojari & Shri Keshav Dubey

…of the assessee and that it was one of the duties of the officers to assist the tax payers in determination of correct amount of tax payable, as per law. Ld. CIT(A) also followed the judgment of Mumbai Bench of ITAT in Chicago Pneumatic (India) Ltd. v. DCIT, 15 SOT 252, wherein relying upon the said circular the Hon'ble Bench had observed that assessing authorities are bound to compute the correct income, and merely for a procedural lapse on technicalities, the assessee should not be compelled to pay more taxes than what is due from him. 4. It is further noted by us that in A.Y 2008-09 an identical claim was ma…

Taruna Maheshwari, Jaipur vs. ITO WD 7(2), Jpr, Jaipur

In the result, the appeal filed by the assessee is partly allowed

ITA 111/JPR/2024[2022-23]Status: DisposedITAT Jaipur03 Jun 2024AY 2022-23

Bench: The Hearing Of Appeal.”

For Appellant: M/S Suhani Maharwal, CAFor Respondent: Smt. Monisha Chaudhary, Addl.CIT
Section 115Section 115BSection 139Section 143(1)Section 3Section 80C

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”SMC” JAIPUR Mk0 ,l- lhrky{eh] U;kf;d lnL; ,oa Jh jkBksM deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, vk;dj vihy la-@ITA No. 111/JP/2024 fu/kZkj.k o"kZ@Assessment Years : 2022-23 cuke Taruna Maheshwari The Income Tax Officer, Vs. 105, Ganga Vihar Colony Tonk Ward-7(2), Jaipur Phatak, Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AHMPJ 1128 R vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : M/S Suhani Maharwal, CA jktLo dh vksj…

Dy. Commissioner of Income Tax, Circle-1(1), Pune vs. Ctr Manufacturing Industries Private Limited, Pune

ITA 998/PUN/2023[2014-15]Status: DisposedITAT Pune27 May 2024AY 2014-15

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.998/Pun/2023 िनधा"रणवष" / Assessment Year : 2014-15 The Dy.Commissioner Ctr Manufacturing Of Income Tax, Circle- Vs Industries Private Limited, 1(1), Pune. Nagar Road, Vadgaon Sheri, S.O. Pune City, Pune – 411014. Pan: Aaacc7256R Appellant/ Revenue Respondent /Assessee

Section 143(3)Section 14ASection 250Section 35Section 35(1)(ii)

…evised return. In this regard, the Respondent places reliance on the following decisions - • CIT Mumbai v. Pruthvi Brokers & Shareholders [2012] 349 ITR 336 (Bombay) (copy enclosed herewith at page no. 608 to 619) • Chicago Pneumatic India Ltd. v. DCIT [2007] 15 SOT 252 (MUM.) (copy enclosed herewith at page no. 620 to 634) Note 1: The Respondent vide revised return filed on 16 September 2015 reduced its weighted deduction claim under section 35(2AB) by ITA No.998/PUN/2023[R]&C.O.No.4/PUN/2024 [A] CTR Manufacturing Industries Private Limited AY 2014-15 Rs.1,80,49,310 on prototypes and claimed depreciation of Rs.…

Concentrix Services India Private Limited (Formerly Known As Minacs Private Limited, Minacs Limited and Aditya Birla Minacs Worldwide Limited), Mumbai vs. DCIT 10(2)(2), Mumbai

In the result, the additional ground of appeal of the assessee is dismissed

ITA 1235/MUM/2015[2010-11]Status: DisposedITAT Mumbai29 Apr 2024AY 2010-11

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.1235/Mum/2015 (निर्धारण वर्ा / Assessment Year: 2010-11) Concentrix Services India बिधम/ Dcit-10(2)(2) Pvt. Ltd Room No. 209, Aayakar Vs. (Formerly Known As Minacs Bhavan, M. K. Road, Pvt. Ltd, Minacs Limited Churchgate, Mumbai- & Aditya Birla Minacs 400020. Worldwide Limited) 9Th Floor, Symphony It Park, Chandivali Farm Road, Andheri (E), Mumbai-400072. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaact1567A (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Chaitanya Joshi & Riken Shah Revenue By: Shri P. Sudhakar Naik सुनवाई की तारीख / Date Of Hearing: 01/04/2024 घोषणा की तारीख /Date Of Pronouncement: 29/04/2024 आदेश / O R D E R Per Aby T. Varkey, Jm: This Appeal Is Filed By The Assessee Against The Assessment Order Passed U/S 143(3) Read With Section 144C(13) Of The Income Tax Act, 1961 (Hereinafter “The Act”) Dated 30.01.2015 Passed By The Dcit- 10(2)(2), Mumbai For Ay. 2010-11, Pursuant To Direction Of The Dispute Resolution Panel-1, Mumbai (Hereinafter “The Ld. Drp”) Dated 27.10.2014. 2. At The Outset, The Ld. Ar Has Brought To Our Notice That This Appeal Of The Assessee Company For The Relevant Year I.E. Ay. 2010-11 Was Partly Allowed By This Tribunal Vide Order Dated 12.06.2023. & Thereafter, The Assessee Preferred A Miscellaneous Application (Ma)

For Appellant: Shri Chaitanya Joshi & Riken ShahFor Respondent: Shri P. Sudhakar Naik
Section 143(3)Section 144C(13)Section 37

…d Another (187 ITR 688) (SC) II. Ultratech Cement Ltd Vs. ACIT (408 ITR 500) (Bom HC) III. CIT Vs. Pruthvi Brokers & Shareholders Pvt. Ltd (349 ITR 336) (Bom HC) IV. Balmukund Acharya Vs. DCIT (176 Taxman 316) (Bom HC) V. Chicago Pneumatic India Ltd Vs. DCIT (15 SOT 252) (Mum Trib) 4 A.Y. 2010-11 M/s. Concentrix Services India Pvt. Ltd. 5. Further, the Ld. AR fairly admitted before us that in the subsequent assessment years i.e. AY. 2011-12 to AY. 2013-14, the assessee had made similar ground of appeal (additional ground of appeal); and this Tribunal was pleased to dismiss the same in assessee’s own case (ITA. N…

The Dy.Commissioner of Income Tax, Circle-1(1)(2), Ahmedabad vs. M/S. Cadila Pharmaceuticals Ltd., Ahmedabad

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

ITA 76/AHD/2020[2009-10]Status: DisposedITAT Ahmedabad17 Apr 2024AY 2009-10

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Bandish Soparkar, and Shri Parin Shah, Ars
Section 250(6)Section 40Section 9(1)(vii)

…Court, the ITAT in the said case had upheld the CIT(A)’s entertaining of claim made for the first before the ld.CIT(A). The assessee had also cited decision in this regard of the ITAT, Mumbai Bench in the case of Chicago Pneumatic India Ltd. Vs. DCIT, (2007) 15 SOT 252 (Mum)(ITAT), and the decision of ITAT, Delhi Bench in the case of ADIT Vs. Global Geophyiscal Services Ltd., 68 SOT 86 (Del.ITAT). 47. The ld.DR was unable to distinguish decisions relied upon by the ld.CIT(A) while admitting the assessee’s claim of deduction under section 35(2AB) of the Act to the tune of Rs.3.21 crores. Therefore, we see no re…

The Dy.Commissioner of Income Tax, Circle-1(1)(2), Ahmedabad vs. M/S. Cadila Pharmaceuticals Ltd., Ahmedabad

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

ITA 73/AHD/2020[2008-09]Status: DisposedITAT Ahmedabad17 Apr 2024AY 2008-09

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Bandish Soparkar, and Shri Parin Shah, Ars
Section 250(6)Section 40Section 9(1)(vii)

…Court, the ITAT in the said case had upheld the CIT(A)’s entertaining of claim made for the first before the ld.CIT(A). The assessee had also cited decision in this regard of the ITAT, Mumbai Bench in the case of Chicago Pneumatic India Ltd. Vs. DCIT, (2007) 15 SOT 252 (Mum)(ITAT), and the decision of ITAT, Delhi Bench in the case of ADIT Vs. Global Geophyiscal Services Ltd., 68 SOT 86 (Del.ITAT). 47. The ld.DR was unable to distinguish decisions relied upon by the ld.CIT(A) while admitting the assessee’s claim of deduction under section 35(2AB) of the Act to the tune of Rs.3.21 crores. Therefore, we see no re…

Cadila Pharmaceuticals Ltd., Ahmedabad vs. The Asst. Commissioner of Income Tax, Circle-1(1)(2), Ahmedabad

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

ITA 52/AHD/2020[2009-10]Status: DisposedITAT Ahmedabad17 Apr 2024AY 2009-10

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Bandish Soparkar, and Shri Parin Shah, Ars
Section 250(6)Section 40Section 9(1)(vii)

…Court, the ITAT in the said case had upheld the CIT(A)’s entertaining of claim made for the first before the ld.CIT(A). The assessee had also cited decision in this regard of the ITAT, Mumbai Bench in the case of Chicago Pneumatic India Ltd. Vs. DCIT, (2007) 15 SOT 252 (Mum)(ITAT), and the decision of ITAT, Delhi Bench in the case of ADIT Vs. Global Geophyiscal Services Ltd., 68 SOT 86 (Del.ITAT). 47. The ld.DR was unable to distinguish decisions relied upon by the ld.CIT(A) while admitting the assessee’s claim of deduction under section 35(2AB) of the Act to the tune of Rs.3.21 crores. Therefore, we see no re…

Cadila Pharmaceuticals Ltd., Ahmedabad vs. The Asst. Commissioner of Income Tax, Circle-1(1)(2), Ahmedabad

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

ITA 51/AHD/2020[2008-09]Status: DisposedITAT Ahmedabad17 Apr 2024AY 2008-09

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Bandish Soparkar, and Shri Parin Shah, Ars
Section 250(6)Section 40Section 9(1)(vii)

…Court, the ITAT in the said case had upheld the CIT(A)’s entertaining of claim made for the first before the ld.CIT(A). The assessee had also cited decision in this regard of the ITAT, Mumbai Bench in the case of Chicago Pneumatic India Ltd. Vs. DCIT, (2007) 15 SOT 252 (Mum)(ITAT), and the decision of ITAT, Delhi Bench in the case of ADIT Vs. Global Geophyiscal Services Ltd., 68 SOT 86 (Del.ITAT). 47. The ld.DR was unable to distinguish decisions relied upon by the ld.CIT(A) while admitting the assessee’s claim of deduction under section 35(2AB) of the Act to the tune of Rs.3.21 crores. Therefore, we see no re…

DCIT, Circle-7(1), Delhi vs. Eicher Motors Limited, Delhi

ITA 3721/DEL/2023[2015-16]Status: DisposedITAT Delhi15 Mar 2024AY 2015-16

Bench: Shri Kul Bharat & Dr. B.R.R. Kumarassessment Year: 2015-16

Section 35

…. Pruthvi Brokers and Shareholders P. Ltd. 349 ITR 336 (Bom.) JCIT v Hero Honda Finlease Ltd.: 115 TTJ 752 (Del. Trib.) SNC-Lavalin/Acres Inc.: 110 TTJ 13 (Del.) CIT vs. Aspentech India P. Ltd.: ITA No. 1233/2011 Chicago Pneumatic India P. Ltd. v DCIT: (2007) 15 SOT 252 Hon'ble Tribunal notwithstanding that the said additional claim was not made in the return of income. Accordingly, the claim of deduction of discount on issue of ESOPs not claimed in the return of income but claimed during the assessment proceedings ought to be allowed. 10.1 Learned counsel submitted that the Tribunal in A.Y. 2013-14 and 2014-15…

Eicher Motors Limited, New Delhi vs. DCIT Circle 7(1) New Delhi, New Delhi

ITA 3525/DEL/2023[2015-16]Status: DisposedITAT Delhi15 Mar 2024AY 2015-16

Bench: Shri Kul Bharat & Dr. B.R.R. Kumarassessment Year: 2015-16

Section 35

…. Pruthvi Brokers and Shareholders P. Ltd. 349 ITR 336 (Bom.) JCIT v Hero Honda Finlease Ltd.: 115 TTJ 752 (Del. Trib.) SNC-Lavalin/Acres Inc.: 110 TTJ 13 (Del.) CIT vs. Aspentech India P. Ltd.: ITA No. 1233/2011 Chicago Pneumatic India P. Ltd. v DCIT: (2007) 15 SOT 252 Hon'ble Tribunal notwithstanding that the said additional claim was not made in the return of income. Accordingly, the claim of deduction of discount on issue of ESOPs not claimed in the return of income but claimed during the assessment proceedings ought to be allowed. 10.1 Learned counsel submitted that the Tribunal in A.Y. 2013-14 and 2014-15…

ACIT, CC - I (2), Chennai vs. M/S. Balaji Hotels & Enterprises Ltd., Chennai

In the result, the appeals filed by the Revenue in ITA Nos

ITA 209/CHNY/2020[2010-11]Status: DisposedITAT Chennai23 Feb 2024AY 2010-11

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri D. Anand, Advocate
Section 139Section 139(5)Section 143(3)

…9/Chny/2020 the information relating to the transaction was on record and duly evidenced as it undisputably was in the instant case. (i). Emerson Network Power India (P) Ltd. vs. ACIT [2009] 27 SOT 593 (mum) (ii). Chicago Pneumatic India Ltd. vs. DCIT [2007| 15 SOT 252 (Mum); and (iii). CIT vs. Ramco International (2009] 180 Taxman 584 (Punj. & Har.) (iy). CBDT Circular No. 14 (XL-35) of 1955 dated April 11, 1955; (u). Dattatraya Gopal Shette vs. CIT [1984] 150 ITR 460 (Bom) (vi). Cholkshi Metal Refinery vs. CIT (1977) 107 ITR 63 (Guj.): (vii). CIT vs. Shri. Someshwar Sahakari Karkhana Ltd. (1989) 177 ITR 443 (B…

ACIT, CC - I (2), Chennai vs. M/S. Balaji Hotels & Enterprises Ltd., Chennai

In the result, the appeals filed by the Revenue in ITA Nos

ITA 208/CHNY/2020[2009-10]Status: DisposedITAT Chennai23 Feb 2024AY 2009-10

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri D. Anand, Advocate
Section 139Section 139(5)Section 143(3)

…9/Chny/2020 the information relating to the transaction was on record and duly evidenced as it undisputably was in the instant case. (i). Emerson Network Power India (P) Ltd. vs. ACIT [2009] 27 SOT 593 (mum) (ii). Chicago Pneumatic India Ltd. vs. DCIT [2007| 15 SOT 252 (Mum); and (iii). CIT vs. Ramco International (2009] 180 Taxman 584 (Punj. & Har.) (iy). CBDT Circular No. 14 (XL-35) of 1955 dated April 11, 1955; (u). Dattatraya Gopal Shette vs. CIT [1984] 150 ITR 460 (Bom) (vi). Cholkshi Metal Refinery vs. CIT (1977) 107 ITR 63 (Guj.): (vii). CIT vs. Shri. Someshwar Sahakari Karkhana Ltd. (1989) 177 ITR 443 (B…

ACIT, CC - I (2), Chennai vs. M/S. Balaji Hotels & Enterprises Ltd., Chennai

In the result, the appeals filed by the Revenue in ITA Nos

ITA 207/CHNY/2020[2008-09]Status: DisposedITAT Chennai23 Feb 2024AY 2008-09

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri D. Anand, Advocate
Section 139Section 139(5)Section 143(3)

…9/Chny/2020 the information relating to the transaction was on record and duly evidenced as it undisputably was in the instant case. (i). Emerson Network Power India (P) Ltd. vs. ACIT [2009] 27 SOT 593 (mum) (ii). Chicago Pneumatic India Ltd. vs. DCIT [2007| 15 SOT 252 (Mum); and (iii). CIT vs. Ramco International (2009] 180 Taxman 584 (Punj. & Har.) (iy). CBDT Circular No. 14 (XL-35) of 1955 dated April 11, 1955; (u). Dattatraya Gopal Shette vs. CIT [1984] 150 ITR 460 (Bom) (vi). Cholkshi Metal Refinery vs. CIT (1977) 107 ITR 63 (Guj.): (vii). CIT vs. Shri. Someshwar Sahakari Karkhana Ltd. (1989) 177 ITR 443 (B…

DCIT-2(3)(1), Mumbai vs. Hdfc Bank Limited, Mumbai

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

ITA 3375/MUM/2023[2016-17]Status: DisposedITAT Mumbai24 Jan 2024AY 2016-17

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar a/w ShriFor Respondent: Shri Biswanath Das, CIT-DR
Section 14ASection 36(1)(viia)

…f the exact data at the time of filing the ITR but was made available later on by the respective authority in the web-site. 9.4.2 As per submission, the assessee has relied upon the decision/judgement given in the case of Chicago Pneumatic India Ltd vs. DCIT (15 SOT 252) (Mum), decision of the Hon'ble Gujarat High Court in case of Choksi Metal Refinery vs. CIT (107 ITR 63), decision of the Hon'ble Delhi HC in the case of CIT v. Natraj Stationery Products (P) Ltd. (2009) 312 ITR 22, decision of the Hon'ble Jurisdictional Bombay High Court in Pruthvi Brokers & Shareholders Pvt. Ltd (2012) 349 ITR 0336 (BOM) and dec…

DCIT 2(3)(1), Mumbai vs. Hdfc Bank Limited, Mumbai

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

ITA 3374/MUM/2023[2017-18]Status: DisposedITAT Mumbai24 Jan 2024AY 2017-18

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar a/w ShriFor Respondent: Shri Biswanath Das, CIT-DR
Section 14ASection 36(1)(viia)

…f the exact data at the time of filing the ITR but was made available later on by the respective authority in the web-site. 9.4.2 As per submission, the assessee has relied upon the decision/judgement given in the case of Chicago Pneumatic India Ltd vs. DCIT (15 SOT 252) (Mum), decision of the Hon'ble Gujarat High Court in case of Choksi Metal Refinery vs. CIT (107 ITR 63), decision of the Hon'ble Delhi HC in the case of CIT v. Natraj Stationery Products (P) Ltd. (2009) 312 ITR 22, decision of the Hon'ble Jurisdictional Bombay High Court in Pruthvi Brokers & Shareholders Pvt. Ltd (2012) 349 ITR 0336 (BOM) and dec…